USDA’s remote audit gives a pass to Poland’s pork inspection system

During the pandemic, virtual inspections of restaurants and domestic food manufacturers became standard. Remote audits of foreign inspection practices are part of that new normal.

USDA’s Food Safety and Inspection Service on Jan. 5 released its remote ongoing verification audit of Poland’s pork products inspection system for May 25 through July 8, 2021.

“Due to the global COVID-19 pandemic, the audit was conducted remotely using video conferences to conduct interviews and records reviews,” according to the audit report. 

More than 4.1 million of Poland’s population of nearly 38 million have reported COVID-19 infections since the start of the pandemic in early 2020. More than 99,000 have died.

“The purpose of the audit was to determine whether Poland’s food safety inspection system governing raw and processed pork products remains equivalent to that of the United States, with the ability to export safe, wholesome, unadulterated products and correctly labeled and packaged,” it said.

 To the United States, Poland currently exports thermally processed, commercially sterile (TPCS) pork; ready-to-eat (RTE) pork fully-cooked without subsequent exposure to the environment; RTE fully-cooked pork; RTE dried pork; RTE acidified/fermented pork (without cooking); raw intact pork; and not ready-to-eat (NRTE) otherwise processed pork.

The audit focused on six system equivalence components, including:

1. Government Oversight (Organization and Administration).
2. Government Statutory Authority and Food Safety and Other Consumer Protection Regulations ( Inspection System Operation, Product Standards, Labeling, and Humane Handling).
3. Government Sanitation.
4. Government Hazard Analysis and Critical Control Point (HACCP) System.
5. Government Chemical Residue Testing Programs.
6. Government Microbiological Testing Programs.

The U.S. FSIS auditors concluded that Poland’s inspection system for raw and processed pork products provides ultimate control, supervision, and enforcement of regulatory requirements. 

Poland’s Central Competent Authority (CCA) has required that establishments certified as eligible to export products to the United States implement sanitary operating procedures and a HACCP system designed to improve the safety of their products. 

Polish authorities have implemented microbiological and chemical residue testing programs to verify its system. An analysis of each component did not identify any systemic findings representing an immediate threat to public health.

In addition to the FSIS Office of International Coordination, USDA’s Animal and Plant Health Inspection Service (APHIS) oversees requirements to control African Swine Fever (ASF) related to pork from Poland.

The audit report also said FSIS:

• reviewed and analyzed GVI’s Self-Reporting Tool (SRT) responses and supporting documentation before the remote equivalence verification audit. During the audit, the FSIS auditors conducted interviews and reviewed records to determine whether Poland’s food safety inspection system governing pork meat products is being implemented as documented in the country’s SRT responses and supporting documentation.
• applied a risk-based procedure that included an analysis of country performance within six equivalence components, product types and volumes, frequency of prior audit-related site visits, point-of-entry (POE) reinspection, and testing results in specific oversight activities of government offices, and testing capacities of laboratories.

 The review process included an analysis of data collected by FSIS over three years and information obtained directly from GVI through the SRT.

“FSIS performed the remote audit to verify that the food safety inspection system meets requirements equivalent to those under the specific provisions of United States laws and regulations, in particular:

• The Federal Meat Inspection Act (21 United States Code [U.S.C.] Section 601 et seq.);
• The Humane Methods of Livestock Slaughter Act (7 U.S.C. Sections 1901-1906); and
• The Meat Inspection Regulations (9 CFR Parts 301 to the end).
• The audit standards applied during the review of Poland’s inspection system for pork meat products included: (1) all applicable legislation originally determined as equivalent by FSIS as part of the initial review process and (2) any subsequent equivalence determinations that FSIS has made under provisions of the World Trade Organization’s Agreement on the Application of Sanitary and Phytosanitary Measures.

FSIS import inspectors performed 100 percent re-inspection for labeling and certification on 359,794,555 pounds of pork meat products from Poland from Dec. 1, 2017, to Feb. 8, 2021. Including:

• 4,018,365 pounds of TPCS pork;
• 12,855,745 pounds of RTE pork fully-cooked without subsequent exposure to the environment;
• 47,620,386 pounds of RTE fully-cooked pork;
• 372,143 pounds of RTE dried pork;
• 339,439 pounds of RTE acidified/fermented pork (without cooking);
• 293,485,511 pounds of raw intact pork; and
• 1,102,966 pounds of NRTE otherwise processed pork exported by Poland to the United States.

Of these amounts, additional types of inspection were performed on 37,251,989 pounds of meat, including:

• 301,772 pounds of TPCS pork;
• 1,634,862 pounds of RTE pork fully-cooked without subsequent exposure to the environment;
• 5,838,741 pounds of RTE fully-cooked pork;
• 51,174 pounds of RTE dried pork;
• 32,671 pounds of RTE acidified/fermented pork (without cooking);
•  29,308,982 pounds of raw intact pork; and
• 83,787 pounds of NRTE otherwise processed pork.

The audit report continues by saying “These additional types of inspection included physical examination, condition of container examination for TPCS products, chemical residue analysis, and testing for microbiological pathogens (Listeria monocytogenes (Lm) and Salmonella in RTE products). Since the previous FSIS audit of Poland in 2019, there have been seven public health critical violations identified at POE, resulting in the rejection of 390,221 pounds of pork products. The principal cause of these rejections was the presence of ingesta. In addition, there were five other consumer protection/non-critical violations related predominately to foreign materials (193,806 pounds). All identified POE violations were limited to two establishments, both of which were selected for in-depth review during the remote audit reflected in this report.”

The audit exit meeting via videoconference was held on July 8, 2021, with the finding that “Poland’s inspection system for raw and processed pork products is organized to provide ultimate control, supervision, and enforcement of regulatory requirements.”

In a brief response to the audit, Katarzyna Piskorz, Poland’s chief veterinary officer, said the project demonstrated “a great understanding of the operation of the meat inspection system in Poland and the implementation of U.S. regulations in Polish establishments of the pork sector approved for export to the indicated market.”

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